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TREASURY DEPARTMENT 
UNITED STATES PUBLIC HEALTH SERVICE 

HUGH S. CUMMING, Surgeon General 



COMMISSION ON MILK 
STANDARDS 

SUMMARY OF REPORTS OF THE COMMISSION ON 

MILK STANDARDS APPOINTED BY THE 

NEW YORK MILK COMMITTEE 



Reprinted from the Public Health Reports, May 10, 1912, pages 673 700 
August 22, 1913, pages 1733-1756; February 16, 1917, pages 271-314 
January 17, 1919, pages 69-71; and December 10, 1920, pages 2955-2958 



REPRINT No. 634 



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1921 






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COMMISSION ON MILK STANDARDS. 

SUMMARY OF REPORTS OF .^CWgjBOH OK .g^JTAHDA.DB APPOINTED 

PREAMBLE. 

Purposes of Milk Standards. 

Proper milk standards are essential to efficient milk control by 
public health authorities. In the first place, health authorities must 
ascertain that the chemical composition corresponds with established 
definitions of milk as food, but their more important duty is to 
prevent the transmission of disease. This means the prevention of the 
transmission by milk, of infant diarrhea, typhoid fever, tuberculosis, 
septic throat infections, scarlet fever, diphtheria, and other infectious 
diseases. In the interests of milk consumers, public health authorities 
must take positive action to prevent the transmission of any of these 
diseases, in addition to their duty of preserving the food value of 
milk. 

The milk producer is interested in proper standards for milk, and 
should support a movement to secure proper standards, for the 
reason that these contribute to the well-being and dignity of the 
milk industry itself. Proper standards, rightly enforced, distinguish 
between the good-milk producer and the bad-milk producer. This 
inevitably will lead to the improvement of dairy farming, and even- 
tually to an increase in the financial prosperity of the milk producer 
himself through better prices for better milk. It will enable the 
producer to get properly paid for the quality of milk he produces, 
and thus put that industry for the first time upon a dependable basis. 

The milk dealer finds the classification of milk, resulting from 
milk standards, to his financial advantage, for the reason that it 
identifies clearly first-class milk and distinguishes it from second- 
class milk. Such a distinction gives to the seller of first-class milk the 
commercial rewards which such milk deserves, and the official label 
creates a market for first-class milk which the dealer alone is unable 
to create. 

For milk consumers, the setting of definite standards accompanied 
by labeling with official control of the labels makes it possible to know 

1 These reports were published in the Public Health Reports, May 10 191 2 DD 67 9 

7 °S : n AUg ;f ' It™' PP " 1733 - 1756 = **• 16. 1917, pp. 271-314; Jan "iT. 1919 "ppVn^ 
and Dec. 10, 1920, pp. 2955-2958. 



4 COMMISSION ON MILK STANDARDS. 

the character of the milk which is purchased, and to distinguish 
good milk from bad milk. The establishment of standards for qual- 
ity, and of labels on retail packages indicating the quality, compels 
the industry not only to purchase milk on a quality basis, but also to 
sell milk on a quality basis. The selling of milk strictly on a quality 
basis, which includes not only chemical composition but sanitary 
character, makes it possible for consumers, by an inspection of the 
label, intelligently to select milk which in quality and price is most 
suitable for their needs. 

Administrative Equipment. 

Standards are useless unless properly guarded and enforced. The 
chief objection that has been raised to a grading system for milk is 
the difficulty of insuring that milk labeled as of a certain grade is 
actually of that grade when sold to the consumer. 

The prime requisite for efficient milk control is that health depart- 
ments shall be adequately equipped with men, money, and laboratory 
facilities. The commission is of the opinion that satisfactory results 
can not be expected from laws when there is not sufficient appropria- 
tion, and when there is no machinery for their enforcement. A sur- 
vey of the money appropriated for milk control shows that in the 
majority of municipalities this is entirely insufficient for public 
needs. 

The key to the solution of the problem of the proper use of grade 
labels is the laboratory. The establishment and operation of an effi- 
cient milk-testing laboratory is commonly supposed to be an item of 
great expense. This, however, the commission is convinced, is a mis- 
take, since there are numerous laboratories scattered all over the land, 
not only private, but public, which are inexpensive and operated at 
low cost. By efficiency methods a large number of tests can be made 
at a very low cost. Even small communities can afford to maintain 
and operate such laboratories. Where for any reason it is not pos- 
sible to do this, it has proved to be practicable for one community to 
enter into laboratory arrangements with another, and even several 
can combine in the use of a common laboratory. 

Grading of Milk. 

There is no escape from the conclusion that milk on the market 
must be graded just as other commodities, such as wheat, grain, beef, 
etc., are graded. The milk merchant must judge not only of the food 
value but also of the sanitary characteristics of the commodity in 
which he deals. There is no good reason for believing that fruit be- 
ginning to decay is particularly unhealthful, but it should not be sold 
on a par with sound fruit. Small apples have as much food value as 



COMMISSION ON MILK STANDARDS. 5 

an equal quantity of large ones, but the latter properly command a 
higher price. So, too, with milk; the high-grade product, fresh and 
cold, will cost more to buy from the producer, and should sell for 
more to the consumer than does the low-grade product. The commis- 
sion's most important work has been the attempt to separate milk 
into grades and classes. The commission has endeavored to make its 
grading system as simple as possible, and at the same time to dis- 
tinguish between milks which are essentially different in their sani- 
tary and other character. The commission is convinced that the ex- 
perience of the last three years has fully demonstrated the value of 
the grading system in the communities in which it has already been 
applied, both from a public-health and an economic standpoint, The 
commission believes that the grading of milk offers a satisfactory 
solution for most of the sanitary and economic problems which have 
hitherto prevented efficient milk control, and that it is feasible for 
small communities as well as large communities to adopt a grading 
system and to secure its benefits. 

CHIEF SUBJECTS CONSIDERED. 

The commission, during its deliberations over a period of nine 
years and on the occasions of its meetings and the numerous meet- 
ings of its subcommittees, has given attention to a great variety of 
subjects. 

The more important conclusions it has reached are the following 

(1) Chemical Standards for Milk. 

The lack of uniformity in chemical standards used by different mu- 
nicipalities and States throughout the United States and Canada has 
led the commission to believe that it is desirable for them to give ex- 
pression to their opinion concerning proper chemical standards for 
milk. The commission recognizes that chemical standards do not in- 
volve public health questions excepting in so far as they safeguard 
the food value of milk. Nevertheless, as milk is a food, chemical 
standards are necessary for defining its nutritive value. 

The chemical standards suggested are the work of a special com- 
mittee, composed of chemists, which has carefully considered the 
natural composition of milk, as well as the Federal and State stand- 
ards already established. The standard of 3.25 per cent fat and 8.5 
per cent solids-not-fat, here proposed, is in accordance with the 
recommendations of the Association of Official Agricultural Chem- 
ists, and has been adopted by the United States Department of 
Agriculture and by a larger number of States than has any other 
standard. (The word "standard" used in connection with milk is 
not intended to imply excellence, but simply to express the lowest 



b COMMISSION ON MILK STANDARDS. 

possible standard or limit that the law permits for a pure or normal 
milk. The same meaning applies to the word used in connection with 
milk products.) 

The Babcock test makes easily practicable the determination of fat 
and solids-not-fat in milk. Such examinations of milk can be readily 
adopted and executed by any health board laboratory at a very mod- 
erate expense. It is believed that such chemical standards as are 
suggested will help to raise the standards of dairying in this country, 
and that the provision regarding substandard milk is a liberal one. 

Cow's milk. — Standard milk should contain not less than 8.5 per 
cent of solids-not-fat and not less than 3.25 per cent of milk fat. 

Skim milk. — Standard skim milk should contain not less than 8.75 
per cent of milk solids. 

Cream. — Standard cream should contain not less than 18 per cent 
of milk fat, and should be free from all constituents foreign to 
normal milk. The percentage of milk fat in cream over or under 
that standard should be stated on the label. 

Adjusted milks. — On the question of milks and creams in which 
the ratio of the fat to the solids-not-fat has been changed by the 
addition to or subtraction of cream or milk fat, the commission has 
hesitated to take a position. On the one hand, they are in favor of 
every procedure which will increase the market for good milk and 
make the most profitable use of every portion of it. On the other, 
they recognize the sensitiveness of milk, the ease with which it is 
contaminated, and the difficulty of controlling such processes as 
standardizing, skimming, homogenizing, souring, adjusting, etc., 
so as to prevent contamination and the use of inferior materials. 
On this subject the commission passed a resolution presented by a 
special committee, as follows: 

The committee believe that it is probably necessary to admit standardized 
and adjusted milk. They believe that such manipulation should be controlled 
and that such milk should be distinctly labeled as to its modifications. 

Milk in which the ratio of the fat to the solids-not-fat has been changed by 
the addition to or subtraction of cream should be labeled " adjusted milk " ; 
the label should show the minimum guaranteed percentage of fat and should 
comply with the same sanitary or chemical requirements as for milk not so 
standardized or modified. 

The committee very carefully considered the subject of the agitation 
which has taken place regarding percentage of solids-not-fat, owing 
to the fact that in some large cities much of the milk contains less 
than 8.5 per cent solids-not-fat. While the commission is disposed 
to admit that these conditions may exist, yet it believes that these 
conditions can be remedied, if not immediately, at least gradually. 
On the other hand, experience has shown that to lower the standard 
would, in a few years, result in the lowering of the general quality 



COMMISSION ON MILK STANDARDS. 7 

of the milk placed on the market, since commerce always tends to 
approach the minimum standard. The commission therefore thinks 
it is unwise to reduce the standard for solids-not-fat below the per- 
centage of 8.5. In those communities where such a standard can 
not be rigidly enforced at the present time, the commission suggests 
that the standard be gradually applied. 

Regulation of market milk on basis of guaranteed percentage com- 
poszhon.-(a) Sellers of milk should be permitted choice of one of 
two systems in handling market milk. They may sell milk first 
under the regular standard; or, second, under a guaranteed 'state- 
ment of composition. 

(b) Any normal milk may be sold if its percentage of fat is 
stated In case the percentage of fat is not stated, the sale should be 
regarded as illegal unless the milk contains at least 3.25 per cent of 
milk fat. 

(c) As a further protection to consumers, it is desirable that when 
the guaranty system is used there be also a minimum guaranty of 
milk solids-not-fat of not less than 8.5 per cent. 

(d) dealers electing to sell milk under the guaranty system should 
be required to state conspicuously the guaranty on all containers in 
which such milk is handled by the dealer or delivered to the con- 
sumer. 

(e) The sale of milk on a guaranty system should be by special 
permission obtained from some proper local authority. 

(2) Bacteria and Bacterial Testing. 

Bacteria and bacterial testing have undoubtedly occupied more of 
the commission's time than any other subject, this topic being con- 
sidered at each of its meetings. Every phase of the relationship of 
bacteria to the sanitary character of milk, as well as to the infec- 
tious diseases transmissible by milk, has been discussed by the seven 
bacteriologists who are members of the commission. The signifi- 
cance of bacteria in milk and methods of bacterial testing havelbeen 
considered m detail, not only from the personal standpoint of the 
bacteriologist but from the administrative standpoint of the eight 
health officers who are members of the commission, as well as the 
two agricultural experts. Because of frequent conferences with 
members of the dairy industry, as well as a knowledge of the action 
taken by municipalities on this subject, it is believed that all phases 
of the relationship of bacteria to milk have been impartially con- 
sidered and that the conclusions reached fairly represent the place 
which bacterial testing should occupy. 



8 COMMISSION ON MILK STANDARDS. 

The commission recognizes that the number of bacteria in milk is 
controlled in the majority of instances by three factors: Dirt, tem- 
perature, or age. Only in the minority of instances are the bac- 
teria of specific diseases present. The routine laboratory methods 
for examining milk have, therefore, as their chief purpose the control 
over dirt, temperature, and age. The difficulties of detecting the 
specific bacteria of disease by laboratory methods prevent labora- 
tories from undertaking such detection as a routine. For this reason, 
laboratory methods are as yet of little value in safeguarding milk 
against specific diseases. The only practical way for protecting 
milk from infection by the bacteria of infectious diseases is by 
medical, veterinary, and sanitary inspection, and by pasteurization. 
Nevertheless, the commission believes that large numbers of bacteria 
that are not specific disease germs have a health significance. 

The routine laboratory methods for determining the total numbers 
of bacteria in milk are believed to furnish a general indication of the 
safety of milk. Small numbers indicate fresh milk produced under 
clean conditions, and kept cool; and such milk is safer than milk 
containing large numbers of bacteria, which is either dirty, warm, 
or stale. In addition to this, the relation which large numbers of 
bacteria bear to the sanitary character of milk is shown by certain 
facts, among which the following are worthy of mention : 

Relation of large numbers of bacteria to infant mortality. — The 
commission believes that the numbers of bacteria in milk have a re- 
lation to the infant mortality, for the following reasons : 

(a) Evidence furnished by clinical observations of groups of 
children fed on milk containing small numbers of bacteria and 
large numbers of bacteria shows a higher death rate in the latter 
than in the former. 

(b) In general, a reduction in infant mortality in cities results 
from a substitution of milk containing small numbers of bacteria for 
milk containing large numbers of bacteria. 

(c) Bacteria causing no specific intestinal infections in adults may 
cause infant diarrhea, and milk containing large numbers of bacteria 
more often contains species capable of setting up intestinal inflamma- 
tion in infants than milk containing small numbers of bacteria. 

Bacterial counts and decency. — On this subject the commission 
passed the following resolutions : 

(a) Because high bacterial counts indicate milk is either warm, 
dirty, or stale, the bacterial count is an indicator of decency in milk 
character, entirely apart from its significance as an indicator of the 
safety of milk. 

(b) In determining the sanitary character of milk and the grade 
in which it belongs, decency must be considered as desirable for its 
own sake, entirely apart from the consideration of safety. Decency 



COMMISSION ON MILK STANDARDS. 9 

is important as a characteristic of foods and drinks, because it gives 
pleasure to the consumption of food, while the lack of decency means 
distaste, displeasure, and even disgust. 

(c) The bacterial count is a sufficiently accurate measure of de- 
cency to justify the health officer in condemning milk with a high 
bacterial count because it is lacking in this characteristic. 

Bacteriological laboratory testing of milk. — On the subject of lab- 
oratory examinations of milk for bacteria the commission believes 
that the interests of public health demand that the control of milk 
supplies, both as to production and distribution, should include regu- 
lar laboratory examinations of milk by bacteriological methods. 
They stated by resolution that — 

Among present available routine laboratory methods for determining the 
sanitary quality of milk the bacterial count occupies first place, and that bac- 
terial standards should be a factor in classifying milk of different degrees of 
excellence. 

The adoption and enforcement of bacterial standards will be more effective 
than any other one thing in improving the sanitary character of public milk 
supplies. The enforcement of these standards can be carried out only by the 
regular and frequent laboratory examinations of milk for the numbers of bac- 
teria it may contain. 

It is of the utmost importance that standard methods should be adopted 
by all laboratories for comparing the bacterial character of milks, since by this 
means only is it possible to grade and classify milks and properly enforce 
bacterial standards. 

Concerning the methods which should be used by milk laboratories 
for determining the numbers of bacteria, the commission unanimously 
resolved : 

That there be adopted as standards for making the bacterial count the stand- 
ard methods of the American Public Health Association Laboratory Section. 

One of the chief objections raised against pasteurization is the 
claim that it is frequently employed to cover filthy methods, the milk 
producer using less care in his methods if he knows that the milk is 
to be subsequently pasteurized. To meet this objection the commis- 
sion believes there should be bacterial standards for raw milk as well 
as bacterial standards for pasteurized milk. In the case of pasteur- 
ized milk, standards should be required of the milk before pasteuriza- 
tion as well as after pasteurization. 

Reliability of bacterial tests. — The commission has considered the 
numerous criticisms that have been raised as to the unreliability of 
bacteriological analyses and has made extensive inquiry as to the 
force of these criticisms. An opinion concerning the reliability of 
laboratory tests for numbers of bacteria has been reached, based on 
voluminous statistics secured for the most part by groups of observers 
working together, as well as by individuals. One of these researches 
31901°— 21 2 



10 COMMISSION ON MILK STANDARDS. 

alone carried out by members of the commission, in cooperation with 
others, included the testing of over 20,000 samples of milk. In other 
instances, repeatedly the same sample of milk was tested 100 times. 
Some variations in the analysis of duplicate samples are inevitable, 
owing to the fact that the bacteria are not in solution, but are floating 
in the milk more or less clustered together in clumps, each of which 
will count only as a single colony. Under such conditions, only an 
approximate agreement can be expected. 

The results of extensive study justify the commission in the con- 
clusion that the analysis of duplicate samples of milk made by routine 
methods in different laboratories may be expected to show an average 
variation of about 28 per cent, with occasional samples of wider 
variation. In some good laboratories the variation may not be 
greater than 10 per cent. Variations in results diminish with the 
numbers of samples analyzed. If five samples of the same milk are 
tested, the results may be relied upon as fairly accurate, and always 
sufficiently accurate to place any particular milk supply unhesitat- 
ingly in grade A, B, or C. The object of bacterial tests of milk 
samples for the numbers of bacteria should be primarily to deter- 
mine the sanitary character of the milk supply from which the sample 
is taken, rather than the character of a single sample of milk. It is 
strongly urged by this commission that no grading of milk should 
be made upon the analysis of single samples, and that no prosecu- 
tions or court cases should be brought upon the bacterial analysis of 
a single sample of milk. 

Interpretation of bacterial tests. — The commission has put its opin- 
ions on this subject in the form of resolutions, as follows: 

Whereas milk is one of the most perishable foods, being extremely susceptible 
to contamination and decomposition; and 

Whereas the milk consumer is justified in demanding that milk should be 
clean, fresh, and cold, in addition to having the element of safety ; and 

Whereas milk which is from healthy cows and is clean, fresh, and which has 
been kept cold, will always have a low bacterial count ; and 

Whereas milk that is dirty, stale, or has been left warm will have a high bacte- 
rial count : Therefore it is resolved : 

First, That the health officer is justified in using the bacterial count as an 
indicator of the degree of care exercised by the producer and dealer in securing 
milk from healthy cows and in keeping the same clean, fresh, and cold ; and 

Second, That the health officer is justified in condemning milk with a high 
bacterial count as being either unhealthy or decomposed, or containing dirt, 
tilth, or the decomposed material as a result of the multiplication of bacteria 
due to age and temperature. 

Third, That the health officer is justified in ruling that large numbers of 
bacteria are a source of possible danger, and that milk containing large numbers 
of bacteria is to be classed as unwholesome, unless it can be shown that the 
bacteria present are of a harmless type, as, for example, the lactic acid bacteria 
in buttermilk or other especially soured milks. 



COMMISSION ON MILK STANDARDS. 11 

Grading by the bacterial count. — Concerning the number of tests 
which should be made in order to determine the grade of a milk sup- 
ply, the commission recommends that the grade into which a milk 
falls shall be determined bacteriologically by at least five consecutive 
bacterial counts, taken over a period of not less than one week nor 
more than one month, and that at least four out of five of these counts 
(80 per cent) must fall below the limit or standard set for the grade 
for which classification is desired. 

The grading of milk has necessarily been based on its sanitary char- 
acter, primarily as determined by the bacterial test. The enforcement 
of grading, therefore, requires the application of the bacterial test in 
a manner sufficiently comprehensive to fairly determine the sanitary 
character of milk so that it may be assigned to the grade in which it 
belongs. Such an administrative system greatly modifies the former 
conception of milk inspection by public health officials. The inspec- 
tion service under the grading system becomes subordinate to the 
bacterial laboratory, or at least must look to the bacterial laboratory 
as a guide. If bacterial tests are recognized as an indication of the 
sanitary character of milk, then the bacterial laboratory tests should 
precede the dairy inspection, since they will point out to the dairy in- 
spector the location of insanitary milk. In the enforcement of the 
grading system, therefore, the milk inspection service should be re- 
organized in such a manner that the bacterial laboratory makes its 
tests first, in order to determine the sanitary character of the various 
milks offered for sale on the city market, and the inspection service 
then takes up the task of discovering the location and causes of the 
defects which the laboratory has discovered, and of remed} 7 ing them. 
The laboratory service and inspection service consequently must be 
centralized under one head and their work thoroughly coordinated in 
order to give the greatest economy and efficiency. 

Bacterial standards for cities of different sizes. — In establishing the 
bacterial standards for a city it is important to take into consider- 
ation the necessary age of the milk, the distance it is hauled, and the 
methods employed in its hauling, in addition to the sanitary condi- 
tion of the milk at its source. It will always be possible for a com- 
munity having very few dairies, easily controlled, which consumes 
milk produced within its own limits, or within transportation of 12 
hours or less from the sources of supply, to insist upon and maintain a 
better bacterial standard than can a city where the milk is hauled 
many miles into town to be consumed within 24 hours after it is 
produced from numerous dairies difficult to control. The small city, 
for those reasons, can and should always maintain a better bacterial 
standard than the large city. 



12 COMMISSION ON MILK STANDARDS. 

Microscopic examination. — Under certain conditions the examina- 
tion of milk for bacteria by the microscopic method serves a useful 
purpose. In its favor it has the advantage of quick and immediate 
results, which, in the hands of reliable workers, have proved to agree 
remarkably well with the results obtained by the plate method. At 
times it gives useful information as to the types of bacteria present. 
On the other hand, the microscopic method fails to distinguish be- 
tween dead and living bacteria, and therefore its value in the exami- 
nation of pasteurized milk is uncertain. Its chief value has been in 
securing quick information regarding the character of raw milk, and 
for this reason it is most useful at the producing and shipping end of 
thjB line rather than at the city end. 

The commission received reports (meeting of Dec. 8, 1918) of 
special tests made in many municipal and private laboratories on 100 
samples of milk taken from the same quart bottle, by the standard 
methods for determining the numbers of bacteria in milk recom- 
mended by the laboratory section of the American Public Health 
Association, and, basing its opinion on these and previous reports, 
the commission passed the following resolution : 

The commission believes that experience has shown that the present standard 
methods of the laboratory section of the A. P. H. A. for making the bacterial 
test of milk, in the hands of properly trained workers, are satisfactory for the 
control of the sanitary character of raw milk on the efficiency of pasteurizing 
machines for destroying bacteria, and for the enforcement of regulations for 
milk control by such grades and standards as have been recommended by this 
commission. 

(3) Pasteurization. 

The pasteurization of milk has been discussed at every meeting held 
by the commission. Its effect on bacteria, its effect on milk, its effect 
on public health, the questions of time and temperature and efficient 
control have all been repeatedly and carefully considered in detail. 
It is believed that the commission has not neglected to take into ac- 
count any of the important contributions which have been made to 
modern knowledge on this subject. In connection with pasteuriza- 
tion the commission has also carefully considered the subject of the 
degrees of safety furnished to milk by the tuberculin testing of 
cattle and medical inspection of dairy employees. 

After a thorough consideration of the various times and tempera- 
tures used, and different forms of apparatus recommended by various 
authorities, the commission decided upon the following definition 
of pasteurization : 

That pasteurization of milk should be between the limits of 140° F. and 
155° F. At 140° F. the minimum exposure should be 20 minutes. For every 



COMMISSION" ON MILK STANDARDS. 13 

degree above 140° F. the time may be reduced by 1 minute. In no case should 
the exposure be for less than 5 minutes. 

In order to allow a margin of safety under commercial conditions, 
the commission recommends that the minimum temperature during 
the period of holding should be made 145° F., and the holding time 
30 minutes. 

Regarding the methods of pasteurization, the commission believes 
that pasteurization in bulk, when properly carried out, has proved 
satisfactory, but that pasteurization in the final container is prefer- 
able. 

The commission thinks that pasteurization is necessary for all milk, 
excepting grade A raw milk. The majority of the commissioners 
voted in favor of the pasteurization of all milk, including grade A 
raw, but since the action was not unanimous the commission recom- 
mended that the pasteurization of grade A raw milk be optional. 

The process of pasteurization should be under efficient supervision. 
The supervision should consist of a personal inspection by the milk 
inspector. The intervals between inspections should be not more than 
one month. The inspector should score the pasteurizing plant by a 
score card. 

Specimens of milk for bacterial analysis should be taken at the 
different stages in pasteurization and subsequent handling. 

All plants handling 1,000 quarts of milk or more a day should be 
required to be equipped with automatic temperature regulators, flow 
regulators, and recording thermometers. The records of these must 
be examined by the department of health not less often than once a 
month. 

Where pasteurization is done with small apparatus not so equipped, 
the proprietor should be required to examine the temperature of the 
milk in the heater at the first and last of each run. and keep a record 
of such temperatures, which record shall be submitted to the de- 
partment of health not less often than once a month. 

For the use of small dealers in cities and small producers for towns 
and villages, efficient pasteurizers costing less than $200 are available. 
The commission, therefore, thinks that milk ordinances for towns and 
villages, as well as for large cities, and also State milk laws, should 
provide compulsory pasteurization, except for grade A raw milk. 

The efficiency of pasteurization should be controlled by bacterial 
tests before and after heating. 

RESOLUTION PASSED AT THE MEETING OF MAY 21, 1920. 

Experience with the pasteurization of milk by the use of the time 
and temperature recommended by this commission has justified in 
every way the selection of the time and temperature which were 



14 COMMISSION ON MILK STANDARDS. 

recommended, and the commission wishes, therefore, to confirm the 
original report on this subject by stating that so far as the commis- 
sion is aware, there is no reason why it should change the recom- 
mendation originally made regarding the proper time and tempera- 
ture of pasteurization of milk. The recommendation originally made 
and published in the Public Health Reports, February 16, 1917, was 
as follows: 

(«) That pasteurization of milk should be between the limits of 140° F. and 
155° F. At 140° F. i lie minimum exposure should be 20 minutes. For every 
degree above 140° F. the time may be reduced by 1 minute. In no case should 
the exposure be for less than 5 minutes. 

(6) In order to allow a marign of safety under commercial conditions, the 
commission recommends that the minimum temperature during the period of 
holding should be made 145° F. and the holding time 30 minutes. 

Scurvy and pasteurization. — The commission has assumed that the 
low temperature of 145° F. for 30 minutes, as recommended by this 
commission for pasteurization, destroys none of the food constituents 
of milk. Inquiry conducted by the New York City Department of 
Health into the records of the infant milk depots, where sometimes 
over 25,000 infants are fed daily on pasteurized milk, appears to bear 
out this assumption. In view of the fact, however, that recent hos- 
pital experimental studies suggest that an exclusive diet of pasteur- 
ized milk may give rise to a subacute scurvy or similar nutritional dis- 
ease in infants, which was entirely prevented, and even cured, by the 
feeding of orange juice or other antiscorbutic food, the commission 
recommends that orange juice be added to the diet of infants that are 
fed on pasteurized milk. The commission wishes also to reaffirm its 
advocacy of the adoption of pasteurization by municipalities as a 
public-health measure. 

In 1917 the commission adopted a resolution to the effect that in 
its opinion the pasteurization of milk at 145° F. for 30 minutes 
destroys none of its food constituents. Since that time there has 
been much careful research on the relation of scurvy to the lack 
of a protective substance in the food. It has been demonstrated to 
the satisfaction of all of the most eminent authorities in nutrition 
that scurvy is due to the lack of a specific dietary factor which 
is easily destroyed by heating, and that milk which has been pas- 
teurized has lost, in part at least, its protective action against this 
disease. 

It has likewise been demonstrated that there may be pronounced 
differences in the value of fresh, unheated milks in their antiscorbutic 
value, depending on the nature of the diet of the cow or lactating 
woman. The antiscorbutic substance is found abundantly only in 
fresh fruits, vegetables, green grass, and other forage. Cooked foods, 



COMMISSION ON MILK STANDARDS. 15 

with certain exceptions, such as tomatoes, are of little value, and the 
milk of a mother whose diet consists largely of cooked or dried or 
preserved foods will not protect her infant against this disease unless 
some substance rich in antiscorbutic properties be included. The 
milk of cows will be more effective as an antiscorbutic food when they 
are fed green foods. 

In view of these new discoveries concerning the possibility of the 
variation of the nutritive value of milks, to some extent, with the 
diet and the seasons, and in view of the possible reduction of the 
food value of milk, with respect to the antiscorbutic factor, in the 
process of pasteurization, the commission recommends that orange 
juice or tomato juice or other antiscorbutic food be added to the 
diet of infants, especially those artificially fed. The commission 
wishes also to reaffirm its advocacy of the adoption of pasteurization 
by municipalities as a public health measure. 

(4) The Tuberculin Testing of Dairy Cows. 

The commission has noted recent developments in connection with 
the manner of administering tuberculin as a diagnostic agent, and 
goes on record as approving the use of tuberculin by the usual sub- 
cutaneous method, always, however, in connection with physical 
diagnosis, and with due regard to the methods prescribed by the 
United States Bureau of Animal Industry. Other methods of using 
tuberculin should be regarded still as under judgment. 

The commission believes that health officers should encourage the 
use of tuberculin as an ideal diagnostic agent when in proper hands, 
and extend its use as rapidly as possible, realizing its practical limita- 
tions owing to the enormous number of cattle and their migrations 
and the limited number of veterinarians qualified to use this test. 

It should be remembered also that tuberculin testing is a means of 
meeting only one of the many problems of milk control. 

(5) Grades of Milk. 

The commission believes that all milk should be classified by divid- 
ing it into three grades, which shall be designated by the letters of the 
alphabet. It is the sense of the commission that the essential part is 
the lettering and that all other words on the label are explanatory. 
In addition to the letters of the alphabet used on caps or labels, the 
use of other terms may be permitted so long as such terms are not the 
cause of deception. Caps and labels shall state whether milk is raw 
or pasteurized. The letter designating the grade to which the milk 
belongs shall be conspicuously displayed on the caps of bottles or the 
labels of cans. 



16 COMMISSION ON MILK STANDARDS. 

The requirements for the three grades shall be as follows : 

GRADE A. 

Raw milk. — Milk of this class shall coine from cows free from disease, as de- 
termined by tuberculin tests and physical examinations by a qualified veteri- 
narian, and shall be produced and handled by employees free from disease, as 
determined by medical inspection of a qualified physician, under sanitary condi- 
tions such that the bacterial count shall not exceed 10,000 per cubic centimeter 
at the time of delivery to the consumer. It is recommended that dairies from 
which this supply is obtained shall score at least 80 on the United States Bureau 
of Animal Industry score card. 

Pasteurized milk. — Milk of this class shall come from cows free from disease, 
as determined by physical examinations by a qualified veterinarian, and shall 
be produced and handled under sanitary conditions such that the bacteria count 
at no time exceeds 200,000 per cubic centimeter. All milk of this class shall be 
pasteurized under official supervision, and the bacterial count shall not exceed 
10.000 per cubic centimeter at the time of delivery to the consumer. It is recom- 
mended that dairies from which this supply is obtained shall score at least 65 
on the United States Bureau of Animal Industry score card. 



Milk of this class shall come from cows free from disease, as determined by 
physical examinations, of which one each year shall be by a qualified veteri- 
narian, and shall be produced and handled under sanitary conditions such that 
the bacterial count at no time exceeds 1,000,000 per cubic centimeter. All milk 
of tbis class shall be pasteurized under official supervision, and the bacterial 
count shall not exceed 50,000 per cubic centimeter when delivered to the con- 
sumer. 

It is recommended that dairies producing grade B milk should be scored, and 
that the health departments or the controlling departments, whatever they may 
be, strive to bring these sources up as rapidly as possible. 



Milk of this class shall come from cows free from disease, as determined by 
physical examinations, and shall include all milk that is produced under condi- 
tions such that the bacterial count is in excess of 1,000,000 per cubic centimeter. 

All milk of this class shall be pasteurized, or heated to a higher temperature, 
and shall contain less than 50,000 bacteria per cubic centimeter when delivered 
to the consumer. 

Whenever any large city or community finds it necessary, on account of the 
length of haul or other peculiar conditions, to allow the sale of grade C milk, 
its sale shall be surrounded by safeguards such as to insure the restriction of 
its use to cooking and manufacturing purposes. 

Grades for small cities and towns. — This commission recognizes 
that because of climate, size of the community, nearness to the sources 
of supply, ease of transportation, and progress already made in im- 
proving the general milk supply, and in educating the dairymen and 



COMMISSION ON MILK STANDARDS. 17 

the public, different communities are in position to secure varying 
degrees of excellence in their standards for the grades of milk. This 
commission, therefore, urges that its standards for grades A, B, and 
C milk be regarded as minimum standards, and that any community 
may adopt higher requirements for its grades if its conditions make 
this feasible and desirable. 

As a guide to health officers in the establishment of grades best 
adapted for their local communities, the following general broad prin- 
ciples are offered : 

(1) A careful prelimnary survey of the milk situaton should be made before 
the requirements of the several grades are adopted. 

(2) No matter how excellent the general milk supply of a community, it is 
not all of a single standard of excellence, hence there are actually different 
grades of milk in every community, and the recognition of such grades is always 
advantageous. 

(3) Grades in any community should always be such as to separate into two, 
or at most three, classes the milk supply of that special community. Where little 
or nothing has been done toward improving the general milk supply, it may be 
desirable to adopt temporary grades (but not below the minimum requirements 
suggested by this commission ) , with a time limit as to when more rigid require- 
ments for the grades will be enforced. 

(4) Grades as adopted in any community should be such as not, under any cir- 
cumstances, to sanction the sale of milk below the minimum standards which it 
is feasible for that community to require. 

(5) Whatever departures are made by any community from the exact definition 
of grades as recommended by this commission, several fundamental principles are 
recognized by the commission as of universal application, and from these there 
should be no variation. These fundamental principles are : 

(a) Grade A milk, in a general way, is milk which complies with requirements 
of such character and degree that, for all practical purposes, no real advantage 
would be gained by further and higher requirements. The standards for this 
grade should therefore be placed high enough to attain this end, but not so high 
as to limit too greatly the supply, or, through unduly raising the price to the 
consumer, to limit too greatly the demand. 

(6) Grade B milk is all the remaining milk of the community which is suitable 
for drinking purposes, after pasteurization, but which does not comply with the 
high requirements for grade A milk. 

(c) Grade C milk is milk which falls below the minimum requirements for 
milk suitable for drinking purposes, even after pasteurization. Its use must be 
confined to cooking and manufacturing purposes. Recognition of this grade of 
milk is not recommended by this commission except in communities in which 
such recognition is an economic necessity. 

(6) The fundamental objects in grading milk are: 

(a) To aid in making safe for human consumption all milk which can legally 
be sold for drinking purposes. 

(6) To distinguish between classes of milk which, while all are safe, are of 
different degrees of excellence in respect to cleanliness and care in handling. 

Each community should, therefore, endeavor to grade its milk sup- 
ply so as best to attain these objects without departure from the broad 
general principles above laid down. 
31901°— 21 3 



18 COMMISSION ON MILK STANDARDS. 

(6) Infected Udders. 

RESOLUTION PASSED AT THE MEETING OF MAY 21, 1920. 

There is occasional danger to human beings from infected udders 
of dairy cows when the udder infection is due to pathogenic bacteria 
of human origin. The danger from udder infection when the bacteria 
are of bovine origin has not yet been determined and is uncertain, 
with the exception of infections from bovine tuberculosis, which are 
known to be dangerous to human beings. Every effort should be 
made to exclude udder infections from dairy herds. Pasteurization 
is a protection because it destroys the bacteria of udder infections in 
milk. 

(7) Cream. 

Cream should be classified in the same grades as milk, in accordance 
with the requirements for the grades of milk, excepting the bacterial 
standards, which in 18 per cent cream shall not exceed five times the 
bacterial standard allowed in the same grade of milk. 

Cream containing other percentages of fat shall be allowed a modi- 
fication of this required bacterial standard in proportion to the change 
in fat. 

(8) Butter. 

There is evidence that much of the butter offered for sale on city 
markets is produced from cream of an inferior grade. The source of 
such cream is in many instances farms where dairying is only inci- 
dental and there are no facilities for sanitary care or refrigeration. 

The stations where this cream is gathered and the plants where it 
is manufactured into butter are often in a most insanitary condition. 
It is believed that sanitation in the production and handling of fluid 
milk is far in advance of sanitation in the butter industry. It is the 
opinion of the commission that steps should be taken at once to bring 
about a reform in the production and handling of butter, and that 
this can best be done by the establishment of standards and grades 
which will distinguish between the superior and inferior product. 
The commission has deliberated on the subject of butter for a period 
of three years, and has made a detailed study through several of its 
standing committees, in addition to conferences with leading repre- 
sentatives of the industry itself. The conclusion of the commission 
on this subject is as follows : 

Definition. — Standard butter is the clean, nonrancid product made by gather- 
ing in any manner the fat of fresh or ripened cream or milk into a mass, which 
also contains a small portion of other milk constituents, with or without salt, 
or added harmless coloring matter, and contains not less than 82 per cent of 
milk fat 



COMMISSION ON MILK STANDARDS. 19 

Butter should be graded as to its sanitary quality and market score, and this 
commission recommends such methods as were recently adopted by law in 
Minnesota and Iowa, whereby the grading of butter on such a basis will be 
started as a voluntary matter. 

In the interest of public health, cream used in the manufacture of butter 
should be pasteurized before being used. 

Grade A butter should be made from grade A milk or cream. 

Grade B butter should be made from grade B milk or cream. 

The sale of butter should be restricted to the product obtained from milk or 
cream that has been produced in such a manner that it could be sold when 
fresh as grade A or grade B milk or cream, as defined by this commission. Such 
milk or cream shall be handled, before manufacture, under strictly sanitary 
conditions by persons free from communicable disease. 

If the sale of butter that is made from an inferior grade of milk or cream 
is permitted, such milk or cream should in all cases be pasteurized, and the 
butter properly labeled. 

If butter is manufactured from rectified milk or cream, the fact shall be so 
stated on the label, and such butter should be considered as of the same class 
as renovated butter. Such butter shall be classified as grade C. 

All containers in which butter is sold shall be marked with the grade of the 
poorest milk or cream that is used, with the name and location of the plant at 
which it is manufactured, and with the date of manufacture. 

(9) Ice Cream. 

The commission has had the subject of ice cream under considera- 
tion for three years. It has been in the hands of a special committee. 

In 1914 several series of bacteriological examinations of ice cream 
were carried out by the bacteriologists of the commission, all of whom 
handed in reports to the commission showing the character of ice 
cream from samples taken in their own localities. There was also 
made available for the commission special work done on this subject 
by the Department of Agriculture at Washington, and by a number 
of public health authorities. 

The commission voted that ice cream shall be regarded as a food 
rather than a confection in the sense of the pure-food law. The com- 
mission also voted that the milk and cream used in the manufacture 
of ice cream should conform to the standards recommended by the 
commission for milk and cream ; also, that all milk and cream used in 
the manufacture of ice cream be pasteurized. 

Concerning the definition of ice cream, which was discussed at 
several meetings, the commission decided upon the following : 

Ice cream is a frozen product made from pasteurized cream and sugar, or 
pasteurized cream and pasteurized milk and sugar, and shall contain not less 
than 8 per cent milk fat. It shall not contain any preservatives, neutralizing 
agent, saccharine, renovated or process butter, fiits, or oils foreign to milk or to 
other ingredients allowed. It may contain wholesome eggs, harmless coloring 
matter, flavoring, sound, clean, mature fruits and nuts, pastries, and approved 
thickening not to exceed 0.5 per cent. 



20 COMMISSION ON MILK STANDARDS. 

Ice cream should be kept frozen until dispensed. Synthetic cream 
(the product made by emulsifying homogenized butter with milk or 
skim milk) should not be recognized for ice cream or other cream pur- 
poses unless the methods and ingredients used be approved by the 
proper authorities. 

Health officers are advised to allow nothing to be sold under the 
name of ice cream unless it comes under the above definition, with the 
further provision that it be manufactured and handled in a sanitary 
manner, the method of determining proper sanitation to be controlled 
by local officials. 

Where there are no bacterial standards, the bacterial content should 
be used as a guide in checking sanitary conditions. 

The use of substitutes for cream, such as emulsified fats other than 
milk fats, should not be allowed for ice cream or other cream purposes. 
If used, the finished product should not be labeled ice cream. 

Grading. — Concerning the character of the products used in ice 
cream, the commission decided to recommend that milk products used 
in the manufacture of ice cream be restricted to the products of the 
grade A and grade B classes. 

Grade A ice cream should be made from grade A milk or cream, and 
the finished product should contain not more than 100,000 bacteria per 
cubic centimeter. 

Grade B ice cream should be made from milk or cream not lower 
than grade B, and the finished product should contain not more than 
1,000,000 bacteria per cubic centimeter. 

The commission recommends the use of a suitable score card in 
grading the sanitary condition of ice-cream factories. 

A suggested score card is included in Appendix 1 of this report. 

(10) Condensed Milk. 

The commission recognizes that in the manufacture of condensed 
milk, evaporated, powdered, and condensed milk products, the sani- 
tary character of the raw milk used affects not only the keeping quali- 
ties but also the safety and decency of the finished product. It is 
clearly to the best interests of the public and the condensed-milk in- 
dustry that condensed milk should be so labeled that the product pre- 
pared from fluid milk of a good quality may be distinguished from 
that prepared from inferior milk. 

The commission therefore recommends the passage of Federal, 
State, and municipal legislation which will permit the manufacturer 
to state upon the label that his product has been prepared from grade 
A milk, and he shall be protected in the use of such a label. 



COMMISSION ON MILK STANDARDS. 21 

(11) Skim Milk. 

The commission passed a resolution regarding the chemical stand- 
ards for skim milk at one of its earliest sessions, recommending that 
skim milk should contain not less than 8.5 per cent of milk solids not 
fat. 

In addition to this, regarding the food value of skim milk, the com- 
mission recommends that : 

Whereas the pressure of the cost of living is increasing rapidly, and vast quan- 
tities of nutritious and available food are now going to waste, and laws pro- 
hibiting the sale of skim milk have no public-health significance ; therefore, the 
commission recommends that the use of skim milk as a food be approved, and 
urges the repeal of laws wherever they exist that prohibit the sale of skim milk 
as a food. 

(12) Buttermilk. 

Concerning buttermilk the commission considered the subject at 
three of its sessions. As a definition of buttermilk the commission 
suggests : 

That the sale of buttermilk should be restricted, first, to the product resulting 
from the churning of milk or cream that is produced under such conditions that 
when fresh it could be sold as grade A or grade B milk or cream, as such grades 
have been defined by this commission ; or, second, to the product resulting from 
the skimming, souring, or treatment in any way of grade A or grade B milk, 
so that it resembles buttermilk (the true character of such imitation or artificial 
buttermilk to be distinctly stated on the container in every case), provided that 
all such buttermilk shall be handled during and after manufacture in a sani- 
tary manner approved by the local health authorities, and that it shall be kept 
at a temperature below 50° F. from the time of manufacture until delivered to 
the consumer. 

The commission recommends that all milk, cream, or skim milk 
entering into the manufacture of buttermilk be pasteurized, unless it 
can be shown that such milk or cream corresponds to grade A raw 
milk. 

All buttermilk should be sold in bottles or cans that are properly 
sealed and labeled, with the name of the manufacturing plant, with 
either the day or date of manufacture, with the grade of milk from 
which it was manufactured, and with a statement as to whether it was 
manufactured from a raw or pasteurized product, and whether it was 
artificially or naturally prepared. 

(13) Dry and Powdered Milks. 

The use of powdered whole milk, skim milk powder, condensed 
or evaporated whole milk or skim milk, butter fat or other fats and 
water, and of machines for recombining, mixing, or emulsifying these 



22 COMMISSION ON MILK STANDARDS. 

materials for the production of manufactured milk or cream was 
considered by a special committee, including some of the food chemists 
of the commission. Their special report on these subjects was adopted 
by the commission and was as follows : 

1. Since the application of the term " synthetic " to mixtures such 
as those under consideration is not entirely consistent with the ac- 
cepted scientific use of the term and is likely to cause confusion, we 
recommend that the use of the term " synthetic " be discouraged and 
that the commission recommend the terms " recombined milk," " re- 
constituted milk, 1 ' on the labels of products made entirely from milk 
constituents, and " artificial milk " or " milk substitute " on the labels 
of products in which any other fat is substituted in whole or in part 
for milk fat. Products which do not contain the proteins and 
mineral elements of milk should not be entitled to the use of any 
designation of which the word milk is a part. 

2. The committee moves the adoption of the following resolution : 
Whereas recent investigations in the science of nutrition have fully demon- 
strated the unique value of milk as a food and the intimate relation hetween 
adequate milk consumption and the support of normal growth or maintenance 
of health and vigor: Be it 

Resolved, That the commission urge upon all concerned with the production 
and distribution of milk, whether as producers, dealers, or public health and 
food control officials, the great Importance of bringing into human consumption 
the largest possible proportion of all wholesome milk products, and to this end 
recommends that the sale of such products as recombined milk should not be 
hampered by any restrictions beyond those absolutely necessary for the preven- 
tion of fraud and the protection of health. 

3. In the case of recombined milk made exclusively from cream or 
butter and milk or skim milk, fresh, condensed or dried, the materials 
having always been maintained in sound condition and not subjected 
to unnecessary heating, the interests of the consumer, in our opinion, 
demand nothing further than that the product as delivered to the 
purchaser shall meet all the requirements as to cleanliness, bacterial 
count, and chemical composition of fresh milk of the same grade or 
class, and shall be labeled in a manner that will correctly indicate 
its true character. 

RESOLUTIONS PASSED AT THE MEETING OF MAY 21, 1920. 

The commission adopted the following report on the subject of 
dried and remade milks : 

Whereas the commission is fully convinced that an increased consumption of 
milk in its various forms would be highly advantageous to the public health; 
and 

Whereas the production and sale of dried and remade milk tends to increase, 
stabilize, and conserve the milk supply; and 

Whereas all evidence now available favors the view that properly prepared 
dried milk may be regarded as of nutritional value equal to milk of light grade, 
and that the vitamine content of dried milk and pasteurized milk is substan- 
tially the same: Therefore be it 



COMMISSION ON MILK STANDARDS. 23 

Resolved, That the commission urge upon the health and food control officials 
a liberal attitude such as shall encourage and not hamper the dried-milk 
industry. 

The commission desires to reaffirm the resolution adopted by the commission 
at the Chicago meeting in 1918, regarding the favorable attitude to be taken 
toward the manufacture and sale of dried or remade milk. It is recognized, 
however, that all products will not be of the same grade and that grading will 
be necessary. 

In our judgment, the sanitary requirements to be adopted for dried and re- 
made milk, as far as applicable, should be the same as those for liquid milk of 
like grade. 

Milk powder which contains less than 25 per cent of its solids in the form of 
milk fat should be labeled " skimmed " or " partly skimmed." 

Milk powder which contains less than 3 per cent of fats in its solids should 
be labeled " skimmed." 

Those containing between 3 and 25 per cent of milk fat in their solids should 
be labeled " partly skimmed." 

The term "milk" should be denied to any product in which the milk fat has 
been wholly or partly substituted by any other fat. 

We shall have to defer other specific recommendations as to the grading of 
dried milk, but recommend the study of grading. The following suggestions 
are made as to labeling : 

First, that the label show the quality of milk before it is dried, in terms of 
our present grades and standards. 

Second, that the label show the approximate time and temperature of heating. 

Third, that if anything has been added to the milk in the process of manu- 
facture or otherwise, its presence and the name and amount of the substance 
added should be stated on the label. 

Fourth, packages of dried milk should be labeled with the date of manu- 
facture. 

(14) Undernourishment in School Children. 

RESOLUTIONS PASSED AT THE MEETING OF DEC. 8, 1918. 

The commission has received from its members reports concerning 
the prices paid for milk to the producer and the prices at which milk 
is sold to the consumer, the quantity of milk sold, and the mortality 
statistics from localities represented by members of the commission, 
including Boston, New York, Philadelphia, Wilmington, Baltimore, 
Toronto, Indianapolis, Chicago, Jacksonville, and others, and it is 
the judgment of the commission — 

(1) That the price of milk to the consumer from 1914 to 1918 has 
in general increased from 50 to 100 per cent. 

(2) That while the quantity of milk consumed has fluctuated in 
the cities from which reports have been received, yet, generally, at the 
present time it is not less than the normal or usual supply. 

(3) That there has been an improvement in infant mortality and 
a lessening in diarrheal diseases under 2 years of age and that this 
improvement has not been checked by the advance in the price of 
milk between i914 and 1918. 



24 COMMISSION ON MILK STANDARDS. 

(4) That evidence presented to the commission indicates the se- 
riousness of undernourishment or malnutrition among children of 
school age. The commission believes that the cause of this is an 
improperly regulated diet due to some extent to poverty and to a 
larger extent to lack of appreciation of the value of milk as compared 
with other foods. 

(5) That the proportionate increase in the price of other foods 
generally has been greater than the increase in the price of milk. 

(6) That at present retail prices, milk is the most economical 
animal food that can be purchased. 

(7) The commission recognized that the results of nutrition investi- 
gations during the past 10 years have demonstrated that satisfactory 
nutrition is to be secured only through the employment of certain 
combinations of foods. It recognizes that milk, eggs, and green 
leafy vegetables are so constituted as to correct, when taken in liberal 
amounts, the deficiencies, from the dietary standpoint, of cereal prod- 
ucts, peas, beans, tubers, edible roots, and meats. Since good nutri- 
tion can not be secured on diets from which milk, eggs, and the leafy 
vegetables are absent, it is of the greatest importance that the use 
of these classes of foods should be extended. 

It is further recognized that among these, milk is the most effective 
and most economical and that milk is the one food for which there 
is no satisfactory substitute. 

RESOLUTION PASSED AT THE MEETING OF MAY 21, 1920. 

The commission, in connection with the school-lunch movement, 
recommended that every effort be made to emphasize the importance 
of good milk in the diet to promote its increased use in all systems 
of school feeding. 

(15) Clarification. 

The process of the clarification of milk has come into such wide use 
that the commission has felt it necessary to take cognizance of it, but 
it does not believe that it should be recommended as a required stand- 
ard method. In its favor are the following points : 

(c) It removes visible dirt. ■ 

(b) It removes inflammatory products, including many of the causative 
germs. 

(c) It performs the work of the strainer, but in a much more efficient manner. 

Against it are the following points : 

(a) It removes visible dirt, but not all disease-producing germs, and hence 
misleads the consumer as to the real purity of the milk. 

(b) It does not remove urine or the soluble portions of feces; nevertheless 
the milk appears clean. 



COMMISSION ON MILK STANDARDS. 25 

(d) It adds another process requiring handling of the milk, complicating the 
situation. 

id) It largely destroys the value of the dirt test, though not more so than 
good straining. 

(e) It breaks up clumps of bacteria and distributes them through the milk. 

(f) The exact nature of the material removed is not yet fully understood. 

(16) Homogenization. 

Concerning the subject of homogenized milk or cream, the commis- 
sion bases its attitude on the principle of correct labeling. It is of 
the opinion that in the compounding of milk or cream no fat other 
than milk fat from the milk in process should be used, and that no 
substance foreign to milk should be added to it. 

The use of condensed milk or other materials for the thickening 
of cream is opposed unless the facts are clearly set forth on the label 
of the retail package. 

Homogenized milk or cream should be marked as such, stating the 
percentage of fat it contains. 

(17) Licenses. 

A milk dealer should be required to have a permit or license to sell 
any grade or class of milk, and to use a label for such grade or class. 
Such permit or license should be granted only after the local health 
board has determined that the milk of the dealer actually belongs to 
the grade, and it should be revoked and the use of the label forbidden 
when it is determined that the milk is not in the grade or class desig- 
nated. 

(18) Score Cards for Dairy Farms. 

RESOLUTION PASSED AT THE MEETING OF OCT. 15, 1917. 

For the purpose of licensing and grading, scoring should be modi- 
fied to include certain specific requirements for the various grades of 
milk rather than a single arbitrary numerical score. 

(19) Labeling. 

All milk should be labeled and marked with the grade in which it 
is to be sold. In dating milk, uniform methods should be adopted. 
Besides the letter of the grade and the words " raw " or " pasteur- 
ized," there should be added sufficient statements to identify the 
milk as to its source and the time at which it was produced, bottled, 
or pasteurized; and no term descriptive of the quality of the milk 
other than the officially adopted grades should be authorized, unless 
such term is of a generally accepted meaning. 



26 COMMISSION ON MILK STANDARDS. 

In dating milk, uniform methods should be adopted for all grades 
of both raw milk and pasteurized milk, using the day of the week 
or the day of the month. 

The sale of milk which is mislabeled or misbranded should be pun- 
ishable by revoking the dealer's license, reducing the milk to a lower 
grade, or by fines, or suitable penalties. 

(20) Service Bureau. 

RESOLUTIONS PASSED AT THE MEETING OF MAY 21, 1020. 

The commission recommends the establishment of a service bureau 
by the New York Milk Committee. This bureau should send a copy 
of the commission's reports to each governor, each State and provin- 
cial health department, each State and provincial food bureau, each 
mayor of cities of more than 10,000 inhabitants, and to each health 
officer of such cities. 

The bureau should offer its services in — 

(a) The drawing of legislative measures relative to milk and milk 
products. 

(b) Furnishing literature and speakers to promote the adoption of 
such legislation. 

The service bureau should get track of agitation having milk legis- 
lation in view throughout the country, through the services of clip- 
ping bureaus, correspondence, and such other measures as are deemed 
wise. 

The service bureau should cooperate with the Surgeon General of 
the United States Public Health Service and appropriate bureaus of 
the Department of Agriculture, the Children's Bureau, and other 
agencies. 

Resolved, That the service bureau write each State health and education 
agency (boards of health, superintendents of education, etc.), suggesting that it 
provide wall charts, slogans, pictures, etc., to hang in each school, setting forth 
the need and advantage of a more abundant use of good milk as a food for 
children and adults. 

That in this letter there should be a suggestion that such pictures, diagrams, 
charts, and slogans be developed in the schools of the State, through school and 
individual competitions. 

APPENDIX 1.— FACTORS OF PRIMARY IMPORTANCE IN DAIRY 
PRACTICE FOR CONTROLLING THE SANITARY CHARACTER OF 
MILK. 

In its last report the commission placed in an appendix detailed 
regulations for the control of sanitary conditions in dairies and milk 
receiving stations. 

The regulations given there have varying degrees of value in con- 
trolling the character of milk. Many add expense to the cost of pro- 



COMMISSION ON MILK STANDARDS. 27 

duction, and some, while they improve external appearances in the 
dairy, do not materially affect the quality of milk. The grading sys- 
tem deals primarily with the character of the product, and the dairy- 
man should give his special attention to such factors as will most 
effectively improve the character of the product. 

Hence, dairy inspectors should aim to place primary emphasis upon 
the factors that most largely affect the quality of the milk. The com- 
mission urges all health officers and dairymen to separate the factors 
of primary importance from those of secondary importance. The 
following statements are not intended to replace more elaborate regu- 
lations given elsewhere, but to show where the primary emphasis 
should be laid and to distinguish the more important measures from 
those that are of secondary importance in controlling the quality 
of milk. 

In what follows it is assumed that other standard regulations are 
adopted, and that no milk is to be shipped from cows evidently dis- 
eased or with sore udders, or milk handled by employees sick with 
any infectious disease or carriers of disease germs. 

Where milk is to be sold in a raw state, it is assumed that all cows 
will be under veterinary supervision and tuberculin tested once each 
year, and dairy employees will be under regular medical inspection. 

Under these condition it is the opinion of the commission that the 
following factors are most essential in putting on the market milk 
which is clean and contains a low bacterial count. 

1. Financial Stimulus. 

This factor underlies all others. Unless the dairyman can be con- 
vinced that it is to his financial advantage to produce clean milk, any 
attempt to purify the milk supply by legal statutes will be largely 
futile. To produce such a financial stimulus some form of grading 
milk is necessary in which the public will have confidence as being 
thoroughly reliable. This will involve: 

1. (a) The health officer. — The milk must be graded by the proper 
authorities, and this grading should include constant bacteriological 
examination of the milk furnished by each producer for the purpose 
of grading. 

(b) The dealer. — The milk should be paid for by the. dealer ac- 
cording to its grade. The most effective results will be obtained so 
far as concerns cleanliness and sanitary character when the dealer 
pays the producer for milk on a scale based upon its bacterial count 
in addition to other factors. 

The dealer should also thoroughly sterilize all milk containers by 
steam before returning them for refilling. It has been found that 
one of the greatest sources of trouble is the fact that the dealer re- 



28 COMMISSION ON MILK STANDARDS. 

turns to the producer cans which are not only not sterilized, but 
sometimes not even washed clean. No producer can furnish good 
milk in such cans, but the dairyman is almost sure to be blamed for a 
condition for which the dealer is wholly responsible. 

2. To produce milk of grade A or B, the producer will find the 
following factors the most efficient in controlling its cleanliness and 
its bacterial count : 

(a) Milking. — Cows should have clean udders. Hands of the milker should 
be clean and dry. A small-topped milk pail should be used. With clean methods 
no strainer is needed, but if one is used it is preferably of cloth (cheese cloth) 
which has been sterilized by boiling. It is important that the same cloth shall 
not be used for the morning's milking and again for the night's milking. Two 
strainer cloths should be boiled, one used for the morning's and the other for 
the night's milking. 

(ft) Sterilizing. — All milk vessels should be washed with a brush and with 
washing soda, or with alkaline powder and water, should be rinsed in clean 
water and sterilized. Where steam is available, this should be used for steril- 
izing, either as a jet of live steam or under pressure. Where steam is not avail- 
able an abundance of boiling water should be used. 

(c) Cooling. — The milk should be cooled promptly to as low a temperature as 
Is feasible with facilities available. Where this is done in a water tank and 
it is desired to stir the milk to facilitate the process, a wooden paddle of any 
kind must not be used. A metal stirrer may be used, which must be thoroughly 
washed and sterilized with boiling water each day. The lower the temperature 
to which the milk can be cooled, the easier it will be to produce milk of low 
bacterial count. 

While other factors in milk production have their influence, ex- 
tended tests show that 90 per cent of the high bacterial counts are 
attributable to the neglect of the above. 

The above sanitary measures have special reference to the preserva- 
tion of the sanitary character of milk during the process of milk pro- 
duction on the dairy farm. It is recognized that in addition to these, 
precautions must be observed in the milk factory or shipping station 
and on the railroad and in the city delivery station. In some cases 
the chief trouble is after the milk has left the dairy. In shipment 
three factors control the quality of the milk at its destination : Time, 
temperature, and cleanliness of utensils. Thorough refrigeration of 
milk in its progress from the dairy farm through the shipping sta- 
tion, on the railroad, and in the city station is essential to prevent 
large multiplication of bacteria. Washing and sterilizing of all ves- 
sels in which milk is contained and of all apparatus with which it 
comes in contact is vital if contaminations are to be prevented that 
can easily destroy the sanitary character of milk which may have 
left the dairy farm in first-class condition. There is very little value 
in the practice of sanitary measures by the dairy farmer if the milk 
in the hands of the dealer is not properly refrigerated and handled in 
a sanitary manner. 



COMMISSION ON MILK STANDARDS. 29 

Score Card for Ice-Cream Manufacturing Plants. 



Allow. 



Location 

Above ground 5 

Free from contaminating surroundings (no score if bad) 3 

Protected from street dust . . . . : 3 

Not connected with any other room 2 

No other business in same establishment 2 

Const ruction 

WeU lighted (natural) 2 

Well ventilated 1 

Thoroughly screened 2 

Water-closet does not open directly into establishment 2 

Separate room for washing utensils 2 

Floor: Smooth, water-tight, well drained 4 

Walls and ceiling: Smooth and tight 2 

Equipment 

Steam at all times 5 

Hot water at all times (no credit unless running hot water) 3 

Sterilizer for utensils 3 

Conned ions for sterilizing apparatus 2 

Pasteurizer: 

Holding machine 4 

Automatic recording device 1 

Refrigeration : Mechanical (proper ice box, 1) 2 

Freezer: Type, connections, etc 2 

Sanitary piping 2 

Washbasins and towels ample 1 

Utensils: 

Condition 1 

Ample for the service 1 

Racks for 1 

Employees: 

Health certificates for 1 

Clean suits provided 1 

Methods 

Freedom from flies 2 

Protection of material: 

Before manufacture 3 

During manufacture 3 

After manufacture 3 

Utensils and apparatus sterilized (washed in hot water, 1) 3 

Cleanliness: 

Floors 3 

Windows 1 

Apparatus 3 

Walls and ceiling 1 

Utensils 3 

Employees 3 

Character of materials used: 

Milk and cream, grade A (grade B, 4; grade C, 1) 6 

Condensed milk, eggs, etc 2 

Thickeners, none used 1 

Artificial coloring, none 1 

Degree of refrigeration of final product 2 

Total , 



30 



COMMISSION OK MILK STANDARDS. 



Time and Temperature for 
/76 > Milk Pasteurization 




20 JO' 40' 

Time in Minutes 



jo 



64 



COMMISSION ON MILK STANDARDS. 31 

APPENDIX 2.— HISTORY OF THE COMMISSION ON MILK STAND- 
ARDS APPOINTED BY THE NEW YORK MILK COMMITTEE. 

Milk Grading Previous to the Commission's Organization. 

In 1907 there was held a milk conference in Washington called by 
the commissioners of the District of Columbia to report upon the 
milk supply of that city. At this conference Dr. A. D. Melvin ottered 
a resolution proposing that milk be classified into three classes: 

Class 1, certified milk ; class 2, inspected milk ; class 3, pasteurized milk. 

In the first two classes the cows were to be tuberculin tested and the 
milk was to have bacterial standards. The conference recommended 
this classification. The proposal was notable because it provided for 
the pasteurization of all milk, with the exception of milk from tuber- 
culin-tested cows, produced under sanitary conditions. 

In 1908 the Board of Health of New York City adopted a classi- 
fication of milk as follows: 

Class 1, milk (ordinary market milk, raw or pasteurized) ; class 2, selected 
milk ; class 3, inspected milk ; class 4, guaranteed milk ; class 5, certified milk. 

Class 1 represented the bulk of the supply, and no provision was 
made requiring either pasteurization or a bacterial standard. 

Organization of the Commission on Milk Standards. 

In 1910, December 2 and 3, the New York Milk Committee held a 
conference of leading milk authorities in America, on milk problems, 
at which the following resolution was adopted : 

Resolved, That pending the adoption of national standards the conference 
on milk problems of the New York Milk Committee indorse the classification 
of milk recommended by A. D. Melvin, CMef of the Bureau of Animal Industry 
of the United States Department of Agriculture, approved by the milk con- 
ference of the District of Columbia, 1907, and published in Circular 114 of the 
Bureau of Animal Industry, and in Bulletins Nos. 41 and 56 of the United States 
Public Health and Marine Hospital Service. 

(This classification designates three kinds of milk — certified; in- 
spected; pasteurized.) 

This same conference also passed the following resolution : 

Whereas it has been demonstrated by the papers and the discussions at this 
conference, held at the invitation of the New York Milk Committee, that it is 
imperative that definite standards and regulations should be adopted to govern 
the production and handling of dairy products for the prevention of disease 
and the saving of lives. 

Resolved, That the New York Milk Committee be requested to invite between 
12 and 20 recognized experts on milk problems to meet in conference, and that 
those experts be asked to make a unanimous report, recommending proper milk 
standards on which Congress or State authorities may formulate milk legisla- 
tion. 



32 COMMISSION ON MILK STANDARDS. 

In accordance with this resolution, in March, 1911, the New York 
Milk Committee, which is a voluntary organization working for the 
improvement of the milk supply of New York City and the reduc- 
tion of infant mortality, invited 20 experts to become members of a 
commission on milk standards. These men were selected from a list 
of more than 200 men of prominence in medicine, sanitation, public 
health, and laboratory work, who were recognized as authorities on 
the milk question. 

The members at the present time are as follows : 

Dr. Carl L. Alsberg, Chief Bureau of Chemistry, United States Department of 
Agriculture, Washington, D. C. 

Dr. John F. Anderson, of E. R. Squibb & Sons, New Brunswick, N. J. 

Dr. B. L. Arms, State bacteriologist, Montgomery, Ala. 

Dr. W. A. Evans, department of preventive medicine, Northwestern University, 
Chicago, 111. 

Dr. Charles J. Hastings, medical officer of health, Toronto, Canada. 

Dr. J. N. Hurty, secretary State board of health, Indianapolis, Ind. 

Dr. E. C. Levy, health officer, Richmond, Va. 

Prof. E. V. McCollum, School of Hygiene and Public Health, Johns Hopkins 
University, Baltimore, Md. 

Dr. J. R. Mohler, Chief Bureau of Animal Industry, United States Department 
of Agriculture, Washington, D. C. 

Dr. J. S. Neff, Narbeth, Pa. 

Dr. Charles E. North, 30 Church Street, New York City. 

Dr. William H. Park, director of laboratories, department of health. New York 
City. 

Mr. R. A. Pearson, president College of Agriculture, Ames, Iowa. 

Dr. M. P. Ravenel, department of preventive medicine, University of Mis- 
souri, Columbia, Mo. 

Prof. M. J. Rosenau, department of preventive medicine and hygiene. Har- 
vard University. Cambridge, Mass. 

Prof. H. C. Sherman, department of chemistry, Columbia University, New 
York City. 

Dr. L. L. Van Slyke, agricultural experiment station, Geneva, N. Y. 

Mr. C. H. Wells, health officer, Montclair, N. J. 

Dr. William C. Woodward, health officer, Washington, D. C. 

In the list of names above there are seven public health officers, six 
bacteriologists, four chemists, and two agricultural experts. Four- 
teen out of the number have been educated as physicians ; three of 
the members have had long practical experience in the milk industry; 
six have been connected with the production and control of certified 
milk. 

Purposes. 

While this commission was created by and its expense is borne by 
the New York milk committee, it has not been the intention of the 
committee that the commission should have the New York City milk 
problem solely in mind. It was desired that the commission should 
make recommendations regarding milk standards and legislation that 
might be adopted by any city or town in the United States or Canada. 



COMMISSION ON MILK STANDARDS. 33 

Meetings. 

The first meeting; of the commission was held at the New York 
Academy of Medicine on May 22, 1911. The subjects discussed 
included bacterial standards, chemical standards, and the grading and 
classification of milk. Several committees were appointed to report 
at the next meeting. 

The second meeting of the commission was held at the New York 
Academy of Medicine, October 5 and 6, 1911, at which the reports 
of standing committees were received and resolutions adopted con- 
cerning bacterial standards, chemical standards, and grades and 
classes of milk. Special committees were appointed to consider cer- 
tain specific matters. The commission tentatively recommended that 
milk should be classified as follows: Certified; inspected; market; 
cooking; that there be bacterial standards; and that the last two 
classes should be pasteurized. 

January 4, 1912, the New York City department of health made 
an amendment to its sanitary code providing for a new classification 
of milk, as follows : 

Grade A, for infants and children, including : Certified, guaranteed, inspected 
(raw), selected (pasteurized) ; grade B, for adults, including: Selected (raw), 
pasteurized ; grade C, for cooking, including both raw and pasteurized. 

It is noteworthy that this grading system made some use of the 
recommendations of the Commission on Milk Standards, but omitted 
any bacterial standards for grade B or grade C milk, and permitted 
the sale of raw, unpasteurized milk in all grades. At the same time 
it was recognized that this action of New York City was a great step 
in advance, and an indication that the commission's work gave 
promise of taking practical form. 

First Report. 

The third meeting of the commission was held at Homer, N. Y., 
January 25, and at the New York Academy of Medicine, January 26 
and 27, 1912. At this meeting minor matters were voted upon and 
preparations made for the publication of a report of all of the com- 
mission's work. The first report appeared in the Public Health Re- 
ports of the United States Public Health Service, volume 27, No. 19, 
May 10, 1912; 70,000 copies of this report were distributed. 

The fourth meeting of the commission was held in Chicago, Octo- 
ber 29 and 30, 1912, at the time of the National Dairy Show. At this 
meeting the commission attended the annual convention of the Inter- 
national Milk Dealers' Association, and took part in a discussion of 
the classification of milk and milk standards with the leading repre- 
sentatives of the milk industry of the United States and Canada. 

The fifth meeting of the commission was held in Richmond, Va., on 
May 2 and 3, 1913. By this time the commission had the benefit of 



34 COMMISSION ON MILK STANDARDS. 

numerous criticisms and suggestions which had been called forth by 
the first provisional report. At this meeting the commission made 
some radical modifications of its standards and grades, as follows : 

(1) That in classifying milk the grades be designated by letters only, and not 
by such words as " certified," " inspected," " selected," etc. 

(2) That the classification be changed to include only three grades: 

Grade A, consisting of two classes, raw milk with a bacterial standard of 
100,000 per c. c, from tuberculin-tested cows (employees medically inspected) ; 
pasteurized milk with a bacterial standard of 100,000 per c. c. before pasteuriza- 
tion and 10,000 per c. c. after pasteurization. 

Grade B, consisting of one class, with a bacterial standard of 1,000,000 before 
pasteurization and 50,000 after pasteurization. 

Grade C, consisting of one class, over 1,000,000 before pasteurization and 
50,000 after pasteurization. 

Second Report. 

The second report of the Commission on Milk Standards was pub- 
lished by the United States Public Health Service in the Public 
Health Reports of August 22, 1913, and contained the new grading 
system as above recommended. This report was indorsed by the 
American Public Health Association at its annual meeting at Colo- 
rado Springs, September 9-13, 1913. 

(January 1, 1914, the New York City Department of Health 
amended their grading system so as to conform in its essential fea- 
tures to the new grading system recommended by the Commission on 
Milk Standards. This was soon followed by action by the New York 
State Department of Health in establishing a grading system for 
all towns and cities in the State. Later on, the cities of Newark, 
N. J., Jersey City, N. J., Richmond, Va., Kansas City, Mo., adopted 
similar though not identical grading systems. The grading of milk 
is also being considered at the present time by the public health 
authorities of several other municipalities as well as States.) 

The sixth meeting of the commission was held at the New York 
Academy of Medicine, April 13, 1914. At this time special attention 
was given to milk products and reports presented by the members 
of their own investigations on the sanitary and bacterial conditions 
of the ice cream and butter in various parts of the United States and 
Canada. 

The seventh meeting of the commission was held in the Hotel Bilt- 
more and the New York Academy of Medicine, May 7 and 8, 1915. 
On this occasion the commission met the officers of a number of 
commercial organizations, including the National Ice Cream Dealers' 
Association, the National Creamery and Butter Makers' Association, 
and the International Milk Dealers' Association. The deliberations 
dealt chiefly with the subjects of butter, ice cream, and other milk 
products and also with the questions of the control of certified milk 
and dairy inspection. 



COMMISSION ON MILK STANDARDS. 35 

A special committee of the commission met in Washington on Janu- 
ary 17, 1916, with the Joint Committee on Definitions and Standards 
appointed by the Bureau of Chemistry of the United States De- 
partment of Agriculture. The object of this meeting was to permit 
the members of the Commission on Milk Standards to present to the 
joint committee the results of the work of the Commission on Milk 
Standards and to urge the Joint Committee on Definitions and Stand- 
ards, which represents the food and dairy commissioners of the 
various States, the agricultural chemists, and the United States De- 
partment of Agriculture, to approve of the adoption of uniform milk 
standards for all of the States and of the bacterial testing and grad- 
ing of milk according to its sanitary character. 

The eighth meeting was held May 19 and 20, 1916, in the New 
York Academy of Medicine. This meeting was especially effective 
because of the extensive work performed by the standing committees 
of the commission, which held their own independent meetings in 
various parts of the United States several weeks in advance of the 
general meeting. As a consequence of this preparatory work each 
committee brought in most complete and extensive reports of the 
subjects with which they had to deal. These subjects included ice 
cream, butter, condensed milk, standards for small communities, the 
significance of bacterial counts, essentials of dairy scoring, adjusted 
milk, clarification, pasteurization, tuberculin testing, and other minor 
matters. This present report is a summary of the conclusions reached 
by the commission as a result of all of the sessions, and may be re- 
garded as superseding the previous reports. 

The ninth meeting was held October 15, 1917, at the Congress 
Hall Hotel, Washington, D. C. Action was taken recommending 
to the Federal Food Administrator, Herbert C. Hoover, that he have 
maintained an adequate supply of cows' milk of proper quality and 
at a reasonable price for maternity and infant feeding. It was pro- 
posed that governmental or other aid be provided for this purpose. 

The tenth meeting was held December 8, 1918, at Chicago, 111. 
At this time the commission considered the existence of under- 
nourishment in children; the importance of milk because of the 
protective substances it contains; the bacterial testing of milk; and 
the use of powdered milk and other products in the production of 
recombined or reconstituted milks. 

The eleventh meeting was held May 20 and 21, 1920, at the New 
York Academy of Medicine. The principal subjects considered at 
this meeting were : Time and temperature of pasteurization ; infected 
udders; milk for school lunches; dried milks; and a service bureau. 



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